Privacy Policy
1. Introduction
1.1 This Privacy Policy (“Policy”) outlines CashUp’s (“CashUp”, “We”, “Us”, or “Ours”) practices in relation to the storage, use, processing, and disclosure of personal data that You have chosen to share with Us when You download and use Our mobile application “CashUp” or use the Services made available on www.cashup.pk (the app is referred to as the “App” and the App and the website are collectively referred to as the “Platform”).
1.2 The services We offer You on or through the Platform are referred to as “Services”, which shall be as defined in the Terms. Unless specifically defined in this Policy, capitalised terms have the same meaning as in Our Terms and Conditions, available at www.cashup.pk (“Terms”). Please read this Policy in consonance with the Terms.
1.3 At CashUp, We are committed to protecting Your personal data and respecting Your privacy. Please read the following terms of the Policy carefully to understand Our practices regarding Your personal data and how We will treat it. This Policy sets out the basis on which any personal data We collect from You, We collect about You, or that You provide to Us, will be processed by Us.
1.4 By providing Us with the consent to process Your personal data, You acknowledge that We will collect, store, use, and disclose Your personal data in accordance with this Policy.
2. The Data We Collect About You
- Identity and profile-related data: first and last name, parents’ name, date of birth, gender, photographs, educational qualifications, purpose of loan, house ownership, employment status, company name, contact information (addresses, email IDs, phone numbers) and marital status.
 - KYC data: identification documents issued by the government or other authorities, including Your Computerized National Identity Card (CNIC), Smart NICOP, Driver’s License, etc.
 - Transaction data: details of transactions that may occur through the Platform or in connection with the Services (e.g., services You have sought or availed, confirmations of such services).
 - Data from SMSs: with Your permission, We collect, transmit and store transactional SMS data from Your phone on Our secured CashUp server to verify and analyse Your financial position, to determine cash flow, credits, income, and spending pattern. We do not collect, read or store any personal SMSs or account details.
 - Financial data: past credit history, income details, details of loans issued or applied for through the Platform, payments and repayments, bank account details, and bank account statements.
 - Device data: IP addresses, browser types and versions, time zone settings, operating systems, and device information; collected and stored on Our secured CashUp server for analytics.
 - App data: installed applications’ information (package names only) to assess creditworthiness and provide customized loan offers; stored on Our secured CashUp server.
 
2.1 We collect, transmit, and store personal data about You on Our secured CashUp server (www.cashup.pk) after obtaining Your consent, to provide You with, or in connection with, the Services. We only collect and process a minimal amount of Your personal data to provide the Services. Such personal data includes:
    2.2 We do not access Your contact list, call logs, telephony functions, or files & media (except to enable You to upload documents). We do not collect Your biometric data. We may request one-time access to camera, microphone, and location (fine and coarse GPS) solely for onboarding/KYC, each time with Your explicit consent. For certain Services, We may need to send SMS to verify Your device and phone number.
    2.3 We are required to collect certain personal data to provide access to the Platform and Services or as required by law/Terms. If You fail to provide requested data, We may be unable to perform Our obligations and may cancel or limit Your access to the Services (or part thereof).
  
3. How We Collect Data About You
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    3.1 Information You provide Us: data (identity, contact, KYC, financial, device) You consent to share when using Our Services or corresponding with Us (email, chat, Platform), including during registration, feature use, data sharing, or support requests. We keep records of such correspondence.
 
3.2 Information We collect about You and Your device: automatically collected each time You visit the Platform or use the Services via tools like cookies.
3.3 Information from third parties and public sources: including partners and analytics providers for fraud checks, improving Services, and offering suitable credit products.
3.4 We do not control personal data You make public (e.g., reviews in app stores). You share at Your own risk; We are not liable for third-party misuse.
4. How We Use Your Personal Data and For What Purposes
- Registering You as a user;
 - Providing the Services;
 - Communicating Service details and processing queries;
 - Facilitating KYC;
 - Facilitating loan applications and credit facilities from regulated entities;
 - Enabling Services by partners (Lenders, Insurance Partners, Third Party Insurance Intermediaries, Partnered Deposit Facilitators, Digital Gold Providers);
 - Managing Our relationship with You, including Service changes;
 - Administering and protecting Our business and Platform (troubleshooting, analytics, testing, internal ops);
 - Sending communications, including WhatsApp business messages and AI-bot-initiated calls;
 - Conducting analytics and monitoring trends;
 - Improving business and delivery models;
 - Performing contractual obligations;
 - Enforcing Our Terms;
 - Marketing communications (including AI-initiated calls);
 - Responding to court orders/legal claims;
 - Ensuring compliance with applicable laws.
 
4.1 We use Your personal data per applicable law in Pakistan, to provide the Services and to comply with legal obligations.
4.2 By using the Services and creating an account, You authorise Us, Our partners (including Lenders, Insurance Partners, Third Party Insurance Intermediaries, Partnered Deposit Facilitators, Digital Gold Providers) and affiliates to contact You regarding Services, credit products, customer support, dispute resolution, and collection services for Lenders.
4.3 Activities that may be undertaken without direct human supervision or control include:
6. Access and Updating Your Personal Data
You warrant that all personal data provided is accurate, up-to-date, and true. We make best efforts to enable review/correction of inaccurate or deficient data (subject to law). We may verify the accuracy of personal data provided.
7. Data Security
7.1 We implement appropriate security measures and access controls, following applicable Pakistani standards and regulations, including Pakistan’s data protection framework (e.g., the Personal Data Protection legislation when in force) and the Prevention of Electronic Crimes Act, 2016 (PECA). Our processes may be audited by third-party cyber security firms.
7.2 When collection is mandatory (e.g., bureau report or loan application), data is encrypted in transit using modern algorithms and encrypted at rest.
7.3 Information exchanged during the Services is transmitted via SSL. Personal information is encrypted and stored wherever possible. No data is shared with third parties unless it is core to serving the end user and user consent is obtained.
7.4 Access to personal information is restricted to employees who need it to provide Services. Employees are trained on security procedures.
7.5 We maintain incident response procedures to detect, analyse, contain, eradicate, and recover from security incidents. If a breach impacts Your data, We will take timely measures and keep You informed as required by law.
8. Data Retention and Destruction
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    For information about Our retention and destruction practices, please refer to the Schedule to this Policy.
  
 
9. Your Legal Rights
- Request erasure of Your personal data, subject to applicable laws and the terms of Services You have availed.
 - Deny consent necessary to process Your personal data (which may impact Our ability to provide Services).
 - Revoke consent previously provided for specific uses, storage, sharing with partners (Lenders, Insurance Partners, Third Party Insurance Intermediaries, Partnered Deposit Facilitators, Digital Gold Providers), and contact permissions, subject to applicable laws and terms.
 - Rectify/update/amend previously provided information to ensure it is accurate, complete, and up to date. Denying/withdrawing consent, exercising the right to be forgotten, or providing inaccurate information may limit access to Services; We may refuse access accordingly.
 - Comply with applicable laws;
 - Enforce Our legal rights; or
 - Provide information required by regulators investigating fraud or illegal activities.
 
9.1 Under certain circumstances, You have the right to:
    9.2 Notwithstanding 9.1 (a) and 9.1 (c), We may retain information to:
      
9.3 Our Lenders, Insurance Partners, Third Party Insurance Intermediaries, Partnered Deposit Facilitators, and Digital Gold Providers may contact You regarding Your potential/actual use of Services, including loan applications and payment of dues. CashUp and Lenders may continue processing Your information if a loan application was sent to a Lender or a loan was availed, until all dues are paid. Lenders may store information as required by law and may require Us to retain information where services (e.g., collections) are outsourced to Us. AI systems/tools (in-house or third-party) may be used for tasks such as payment reminders and, for this purpose, Your information may be shared with such systems.
    
9.4 To exercise rights, email Us (Section 15) with details of the right(s) and the personal data You believe We hold/process to help locate it. We may request additional information.
    
9.5 We aim to reply within thirty (30) days of the request. If We cannot respond within this timeframe, We will inform You.
  
10. Transfer of Personal Data
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    10.1 All Your data, including financial data collected by Us, is stored on systems located in Pakistan. We do not transfer Your personal data to any third country.
 
10.2 We share information with Lenders and third parties to contact You regarding loan products You express interest in, complete loan applications, perform KYC, collect KYC documents, conduct bank authentication and employment checks, and for loan repayment purposes. We also share information with Insurance Partners, Third Party Insurance Intermediaries, Partnered Deposit Facilitators, and Digital Gold Providers who facilitate Services.
11. Links to Third Party Websites
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    Our Services may contain services provided by or links to websites of partner networks, service providers, financial institutions, advertisers, and affiliates (“Third Party Services”). Such services are governed by their own privacy policies. We are not responsible for those policies or for personal data collected through Third Party Services. Please review their policies before submitting personal data or using their services.
  
 
13. Business Transitions
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    In the event of a business transition (merger, acquisition, sale of assets), Your personal data may be among the assets transferred.
  
 
14. Change in Privacy Policy
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    14.1 We keep this Policy under regular review and may amend it from time to time at Our sole discretion.
 
14.2 Changes will be posted on this page and, where appropriate, notified to You by email or SMS.
15. Grievance Officer
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    15.1 You may contact Us with any enquiry relating to this Policy or Your personal data.
 
15.2 Email: info@cashup.pk
16. Governing Law and Dispute Resolution
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    The provisions of governing law and dispute resolution specified in the Terms apply to this Privacy Policy.
  
 
info@cashup.com.pk